Administrative Law

Tender Eligibility: 'Previous Financial Year' Must Be Reasonably Interpreted

Supreme Court rules tender conditions must be interpreted reasonably considering statutory deadlines - highest bidder wrongly excluded for not submitting ITR that wasn't yet due

Case Reference: M/S Shanti Construction Pvt. Ltd. vs The State of Odisha & Ors (Civil Appeal No. 5829 of 2023) Decided by: Supreme Court of India Date: November 7, 2025

❓ Question

IF YOU SUBMIT A TENDER BID IN JULY 2022 WITH INCOME TAX RETURN FOR FINANCIAL YEAR 2020-2021, CAN THE GOVERNMENT REJECT YOUR BID FOR NOT SUBMITTING ITR FOR 2021-2022 WHEN THE STATUTORY DEADLINE FOR FILING THAT RETURN IS OCTOBER 31, 2022?

✅ Answer

NO, THEY CANNOT. The Supreme Court has ruled that tender conditions must be interpreted reasonably considering statutory deadlines. When a tender is floated in July 2022, the "previous Financial Year" reasonably means 2020-2021, not 2021-2022 for which the statutory filing deadline hasn't expired.

⚖️ Understanding the Legal Principles

🔹 Reasonable Interpretation Principle

  • Tender conditions must be interpreted reasonably
  • Consider statutory deadlines and practical realities
  • Interpretation should advance tender objectives
  • Avoid narrow technical interpretations

🔹 Previous Financial Year Definition

  • Must be read in harmony with Income Tax Act
  • Consider statutory filing deadlines
  • Year immediately preceding is reasonable
  • Cannot expect submission of ITR not yet due

🔹 Public Interest Protection

  • Public tenders aim to maximize public value
  • Excluding highest bidder harms public exchequer
  • Natural resources must yield maximum revenue
  • State acts as trustee of public wealth

🔹 Judicial Review Standards

  • Courts can intervene in arbitrary interpretations
  • Decision-making process must be fair and rational
  • Narrow competition requires court scrutiny
  • Public interest justifies judicial intervention

📜 Key Legal Timeline

July 11, 2022

Tender Notice: Tehsildar issues auction notice for sand quarry lease

July 18, 2022

Bid Submission: 20 bidders submit bids including Shanti Construction (Rs.2127.27/m³) and successful bidder (Rs.1250/m³)

July 19, 2022

Tender Committee Meeting: Shanti Construction's bid declared non-responsive for not submitting ITR 2021-2022

July 25, 2022

Form-F Issued: Successful bidder receives Form-F and deposits Rs.1.26 crore

August 10, 2022

Writ Petition Filed: Shanti Construction challenges tender award in High Court

March 1, 2023

High Court Judgment: Upholds bid rejection but directs successful bidder to match highest price

March 29, 2023

Supreme Court Interim Order: Grants status quo on contract

November 7, 2025

Supreme Court Judgment: Sets aside High Court order, orders fresh tender

🧭 Your Action Plan: Tender Eligibility Issues

📝 If Your Bid is Rejected on Technical Grounds

✅ Step 1: Verify Reasonable Interpretation

  • Check if interpretation considers statutory deadlines
  • Verify if practical realities were considered
  • Assess if interpretation advances tender objectives
  • Document all communications with authorities

✅ Step 2: Calculate Public Interest Impact

  • Quantify financial loss to public exchequer
  • Document how exclusion harms competition
  • Show how interpretation defeats tender purpose
  • Gather evidence of arbitrary decision-making

⚖️ Key Legal Arguments to Make

Legal Argument Basis in Law Application in Your Case
Reasonable Interpretation Article 14 Constitution Tender conditions must be interpreted reasonably considering practical realities
Public Interest Protection Public Trust Doctrine Excluding highest bidder harms public revenue from natural resources
Harmonious Construction Rule of Interpretation Tender rules must be read with Income Tax Act deadlines
Arbitrary State Action Article 14 Constitution Narrow technical interpretation excluding competition is arbitrary

⚖️ If Facing Legal Challenges

✅ Cite Relevant Precedents

  • TATA Cellular vs Union of India (1994)
  • Michigan Rubber vs State of Karnataka (2012)
  • Banshidhar Construction vs Bharat Coking Coal (2024)
  • Natural Resources Allocation, In Re (2012)

📘 Key Legal Terms Explained

Previous Financial Year

The financial year immediately preceding the current financial year, to be interpreted reasonably considering statutory filing deadlines.

Public Trust Doctrine

Legal principle that natural resources are held in trust by the State for public benefit and must yield maximum public value.

Arbitrary State Action

Government action that lacks rationality, fairness, or reasonableness, violating Article 14 of the Constitution.

Harmonious Construction

Interpretation principle where different laws on the same subject should be read together to avoid conflicts.

Judicial Review

Court's power to review government actions to ensure they comply with constitutional principles and laws.

🚨 What to Avoid in Tender Cases

❌ Don't Accept Narrow Technical Interpretations

  • Don't accept interpretations ignoring statutory deadlines
  • Avoid giving up without challenging arbitrary decisions
  • Don't ignore financial impact on public exchequer
  • Avoid delays in legal challenges

❌ Don't Overlook Public Interest Arguments

  • Don't focus only on technical compliance
  • Avoid missing revenue maximization arguments
  • Don't ignore competition reduction impact
  • Avoid weak documentation of financial impact

💡 Core Takeaway from the Supreme Court

"The reasonable understanding of the term 'previous Financial Year' must therefore, be treated to mean the year immediately preceding Financial Year... The Tender Committee has erroneously interpreted the tender condition which excludes the highest bidder and defeats the purpose of the tender."

This judgment establishes that tender conditions must be interpreted reasonably, considering statutory deadlines and practical realities. It protects bidders from arbitrary exclusions based on narrow technical interpretations and ensures that public tenders for natural resources achieve their fundamental purpose of maximizing public revenue through fair competition.

📞 When to Seek Professional Help

👨‍⚖️ Legal Counsel Essential For

  • Complex tender eligibility disputes
  • Cases involving substantial financial stakes
  • Constitutional challenges to tender conditions
  • Appeals against High Court decisions
  • When public interest arguments are crucial

📝 You Can Handle With Support

  • Initial tender application procedures
  • Basic compliance with tender conditions
  • Documenting arbitrary decision-making
  • Calculating financial impact of exclusions
  • Initial representations to authorities

⚠️ DISCLAIMER

This content is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for specific legal guidance. The information provided is based on judicial interpretation and may be subject to changes in law.

🌿 LegalEcoSys Mission

Making Supreme Court judgments accessible and actionable for every Indian citizen navigating legal challenges.

This roadmap decodes a complex administrative law judgment to help businesses and citizens understand their rights in government tender processes. It empowers them to challenge arbitrary exclusions and ensure fair competition while protecting public interest in natural resource management.